Md. Dep't of State Police v. Md. State Conf. of NAACP Branches
Annotate this CaseThe Maryland State Conference of NAACP Branches (NAACP), pursuant to the Public Information Act, requested certain records from the Maryland State Police Department (State Police) to ensure State Police officers did not engage in racial profiling during traffic stops and searches. Although the State Police did provide the NAACP with reports detailing the number and status of racial profiling complaints, the reports did not contain information concerning the State Police's own internal investigations of these complaints, as it considered those records portions of personnel files. The circuit court concluded that the records constituted personnel records but that they should be disclosed with redaction of names and identification. The court of special appeals held that the unredacted records were not exempt from disclosure, as the files did not constitute personnel records of an individual. The Court of Appeals affirmed but for different reasons, holding (1) the disclosure of unredacted records was not properly before the court of special appeals; and (2) the redacted records were not personnel records, and therefore, the circuit court did not err in its judgment.
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